The American Society for Microbiology (ASM), the largest single life science society with over 42,000 members, is writing to comment on legislation which you recently introduced, the Strategies to Address Antimicrobial Resistance Act (STAAR), S. 2313. The ASM appreciates and supports your efforts to address the growing public health problem of antimicrobial resistant infections.

Comments on the STAAR bill, S 2313:

We believe the STAAR Act will help strengthen federal agency activities begun in 1999 with the establishment of the interagency Antimicrobial Resistance Task Force. Reauthorization of the Task Force in the proposed legislation should help reinvigorate important efforts to implement the Public Health Action Plan to Combat Antimicrobial Resistance, initiated in 2001. The Antimicrobial Resistance Plan focuses on surveillance, prevention and control, and research and product development, all of which need enhanced attention and resources.

The STAAR Act creates an Office of Antimicrobial Resistance in the Department of Health and Human Services. We suggest that an alternative approach should be considered making the Centers for Disease Control and Prevention (CDC) the lead agency for the Task Force and the Action Plan. The CDC cochairs the Task Force and was instrumental in formulating the Action Plan. Unfortunately, the CDC funding level of $17 million for antimicrobial resistance is woefully low and may be reduced by almost 6 percent in FY 2008. We recommend that additional resources for antimicrobial resistance of at least $33 million in FY 2008 and $65 million in FY 2009 be provided to CDC.

The STAAR Act recognizes that the problem of antimicrobial resistance requires cooperative partnerships and crucial input from nonfederal stakeholders, including healthcare organizations, pharmaceutical companies, agricultural producers, professional societies, academic institutions, state and local health agencies and consumer groups. We support the legislation’s provision to create a Public Health Antimicrobial Advisory Board of outside experts who can provide input to the interagency Action Plan.

We strongly support the provisions in the proposed bill to collect and disseminate data on the amount of specific antimicrobial products being used in humans and animals. This information will aid our understanding of risks of antimicrobial use in the development of resistance and help guide planning to address antimicrobial use and policy. It will be very important to provide adequate resources to those agencies responsible for collecting the data and providing oversight regarding validity of the data. The process for collecting accurate data will be time and resource intensive and the costs cannot be borne entirely by the manufacturers of the antibiotics.

Section 5 of the STAAR Act establishes a sentinel surveillance system through the CDC and 10 sites to track resistant pathogens using 10 geographic sites around the United States. We believe this section should be revised to recognize and enhance support for current surveillance programs through the CDC Emerging Infections Programs (EIPs) to avoid duplicating or diluting the effective programs and networks that already exist. Since adoption of the Action Plan in 2001, the CDC has made significant progress in the collection of antimicrobial resistance incidence data in the United States, with the design and implementation of a national surveillance plan and new procedures for monitoring patterns of antimicrobial use. Participants at the federal, state and local levels have added data collection for emerging threats like methicillin-resistant Staphylococcus aureus (MRSA).

We encourage Congress to consider drug resistant issues beyond those addressed in the STAAR legislation. Because so many of our meats, vegetables, and seafood are imported today, antibiotic usage outside the United States presents a greater challenge than ever in controlling the problems in this country. The FDA and other relevant agencies must have the resources to participate in a meaningful way to establish international standards and play an active role in establishing policies set by other governments and the World Health Organization (WHO).

Domestically, we recommend increased support for prevention, detection and control of antimicrobial resistant infections. It is crucial to achieve appropriate use of antimicrobials and prevent transmission of infections in healthcare and community settings. To accomplish these goals, the CDC, USDA, and FDA must have adequate funding and personnel. It is also important to provide greater funding for basic, clinical and epidemiologic research programs at the National Institutes of Health (NIH). Research in bacteriology, epidemiology, immunology and other antimicrobial resistant areas of research supported by the National Institute of Allergy and Infectious Diseases (NIAID) underlie the Task Force strategy to discover optimal ways to prevent transmission occurrence and to develop countermeasures against drug resistance. Projected funding for antimicrobial resistance research by NIAID is far less than needed. We recommend an additional $100 million in new funding for NIAID in FY 2008 and $200 million more in FY 2009.

We appreciate the opportunity to comment on this important legislation and offer our assistance to Congress as it considers legislation to address antimicrobial resistance.

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